2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-004 GEAR UP?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.334 Award Year: 2022 Questioned Costs: None Condition During our testing of the GEAR UP program at ENMU-Roswell for internal control requirements for eligibility, for 15 of the 40 students tested, these students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria A system of internal control needs to provide reasonable assurance that objectives of internal control over compliance requirements relating to compliance with federal statutes, regulations, and the terms and conditions of Federal awards will be achieved. Part 6 of the Compliance Supplement states that the objectives of internal control over the compliance requirements for federal awards (2 CFR 200.62) are as follows: Transactions are properly recorded and accounted for in order to (a) permit the preparation of reliable financial statements and federal reports, (b) maintain accountability over assets, and (c) demonstrate compliance with federal statutes, regulations, and the terms and conditions of the federal award. Transactions are executed in compliance with (a) federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program, and (b) any other federal statutes and regulations identified in the Compliance Supplement. Funds, property, and other assets are safeguarded against loss from unauthorized use of disposition. Effect By allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Recordkeeping of these documents appears to have not been properly maintained. The program experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-002 (2021-001) STUDENT FINANCIAL AID ? ENROLLMENT REPORTING (PORTALES CAMPUS) ? Repeated and Modified (Significant Deficiency and Other Non-compliance) Title: Student Financial Assistance Cluster Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.007, 84.033, 84.063, 84.268, 84.379 Award Year: 2022 Questioned Costs: None Condition The University uses a Clearinghouse to report required enrollment changes. The Clearinghouse then provides this enrollment information to the National Student Loan Database System (NSLDS). Though a Clearinghouse is used to facilitate NSLDS reporting, the University has the ultimate responsibility to ensure that student?s status is reported correctly in the NSLDS database. During our testing of the Student Financial Assistance program at ENMU-Portales for the compliance requirements under Enrollment Reporting, we noted that 2 out of 28 students tested were not properly reported or not reported to the National Student Loan Database System (NSLDS) when they graduated. A subsequent matching of all student?s enrollment reported to the NSLDS for the Portales Campus for fiscal year 2022 resulted in additional student?s enrollment reported incorrectly in NSLDS. The University did make progress in the current year as the Roswell campus put in place sufficient controls to ensure that the NSLDS database is correct. Criteria Per 34 CFR section 685.309, schools must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless a roster will be submitted within 60 days, enrollment information must be reported within 30 days when attendance changes for students. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Effect By not reporting the students? enrollment change as required, the University is not in compliance with program requirements. The effective management of the NSLDS program is dependent on timely and accurate reporting from participating institutions. Not reporting enrollment changes timely results in the NSLDS database not matching University?s records. Cause At ENMU Portales, the differences appear to have been caused by data entry errors to the Clearinghouse and not verifying the transmission of all data from the Clearinghouse to the NSLDS. Recommendation We recommend that the University develop and implement policies and procedures to ensure that all students with enrollment changes are reported timely and accurately to NSLDS as required and that a secondary review be used to ensure that all students needing to be reported have been. A team effort is needed to assure all compliance requirements over the Student Financial Aid program are met as required.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.
2022-004 GEAR UP?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.334 Award Year: 2022 Questioned Costs: None Condition During our testing of the GEAR UP program at ENMU-Roswell for internal control requirements for eligibility, for 15 of the 40 students tested, these students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria A system of internal control needs to provide reasonable assurance that objectives of internal control over compliance requirements relating to compliance with federal statutes, regulations, and the terms and conditions of Federal awards will be achieved. Part 6 of the Compliance Supplement states that the objectives of internal control over the compliance requirements for federal awards (2 CFR 200.62) are as follows: Transactions are properly recorded and accounted for in order to (a) permit the preparation of reliable financial statements and federal reports, (b) maintain accountability over assets, and (c) demonstrate compliance with federal statutes, regulations, and the terms and conditions of the federal award. Transactions are executed in compliance with (a) federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program, and (b) any other federal statutes and regulations identified in the Compliance Supplement. Funds, property, and other assets are safeguarded against loss from unauthorized use of disposition. Effect By allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Recordkeeping of these documents appears to have not been properly maintained. The program experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.